The request for internal review lays out evidence that the Commission's methodologies disregard current science and international norms for quantification, monitoring and sustainability of bio-CCS and biochar, ignoring impacts on forests and agricultural lands.
It further warns the Commission's approach weakens the integrity of the EU’s carbon removal framework and undermines EU climate targets by promoting activities that could actually increase CO2 emissions, instead of removing CO2 from the atmosphere. This will divert investment away from more reliable carbon removals just as the Commission is assessing whether to use these removals to offset fossil emissions in the EU Emissions Trading System (ETS).
The European Commission has up to 22 weeks to reply to the request, according to article 10(3) of the Aarhus Regulation, providing reasons as to why it is refusing or accepting the proposed grounds for review of its act. If refused, an action for annulment of that decision can be brought by the NGOs before the EU General Court.
Marlène Ramón Hernández, Policy expert in carbon removals at Carbon Market Watch said, “Both within and outside of the expert group, environmental organisations have consistently put forward recommendations to improve the design of these methodologies. Yet the Commission took a different approach, leaving us with flawed methodologies that do not even comply with the original CRCF mandate. We hope that this request for internal review will help bring the integrity these methodologies so desperately need.”